20080879 Ver 2_Staff Comments_20130814

Strickland, Bev
From: Kulz, Eric
Sent: Wednesday, August 14, 2013 1:46 PM
To: Cranford, Chuck
Cc: Strickland, Bev
Subject: Logan Creek - Jackson Co. ( #08 -0879 v2)
Hey Chuck:
I heard Susan was retiring so I assume you will once again be re- shuffling WL projects around. Please forward as you see
fit. Also feel free to have your staff call if they have any questions.
This is an EEP FDP that was first submitted and approved in 2008. The project was reconfigured due to some type of
legal issue with the property owner, which used some of the proposed EEP project for its own mitigation purposes. They
have added /changed some additional restoration /enhancement to make up the credits lost. That is a little bit of a white
flag there.
Other issues I noticed were that the original plan discussed the presence of some wetlands within the floodplain of
Logan Creek, but the new plan did not appear to address these. They are shown on the plan sheets, and the PCN notes
approx. 2 acres of WLs on the site, but the plan does not address potential impacts to the wetlands. Maybe I missed
something.
Section 10.0 — Long -Term Management. The plan says the project will go to the DENR stewardship, but then goes on to
say that it may instead go to the Highlands- Cashiers Land Trust. I think we would prefer EEP stewardship, as there are
currently or are going to be managed trails that enter the easement. I am not sure if they are looking to the land trust
because they think DENR stewardship may not like the trails. I am concerned about the level of management of the
trails in the future, as the buffers are fairly narrow at some points, and the presence of trails may actually compromise
stream stability(see plan sheet 14 of 26).
Also, based on the width of some of the buffers, some credit adjustment may be warranted.
The planting list in the mitigation plan and the planting list in the plan sheets are somewhat different. The list in Table 2
of the mit plan includes planting Rhododendron maximum, which the mit plan contends is part of the stability problem
along the existing stream (shallow roots). Perhaps this species should be omitted.
Eric W. Kulz
Environmental Senior Specialist
N.C. Division of Water Resources — Water Quality Programs
Wetlands, Buffers, Stormwater - Compliance & Permitting Unit
1650 MSC
Raleigh, NC 27699 -1650
Phone: [phone]
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